News & Analysis as of

Standing Job Applicants Article III

Orrick, Herrington & Sutcliffe LLP

Massachusetts State Appeals Court orders a consumer has standing to sue in state court under the FCRA without federal standing

On January 11, the Massachusetts Court of Appeals ordered that an employee has standing to sue in state court, despite lacking standing to sue in a federal court. The employee (plaintiff) sued a prospective employer for...more

Troutman Pepper

Calif. FCRA Ruling Boosts Technical Claim Defense

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A significant decision from a California state appeals court has shifted the legal landscape for technical Fair Credit Reporting Act claims brought in California state court in favor of defendants. Originally published in...more

Ballard Spahr LLP

Eighth Circuit finds that class-action FCRA plaintiff lacks Article III standing under Spokeo

Ballard Spahr LLP on

The Eighth Circuit reiterated in a decision last month that trial courts must distinguish between FCRA plaintiffs who have suffered concrete harm and plaintiffs who merely seek to collect statutorily allowed damages as a way...more

Burr & Forman

Eighth Circuit Dismisses FCRA Class Action Due to Lack of Standing

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Following the Supreme Court’s decision in Spokeo, Inc. v. Robins, 578 U.S. 330 (2016), federal courts have continued to examine what is an injury in fact under the Fair Credit Reporting Act (“FCRA”). On April 4, 2022, the...more

Troutman Pepper

Pennsylvania Federal Court Finds Lack of Article III Standing in Purely Procedural FCRA Violation and Dismisses Putative Class

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On July 27, 2020, the Eastern District of Pennsylvania confirmed that a plaintiff lacks Article III standing to state a claim for violation of the Fair Credit Reporting Act (“FCRA”) premised solely on the failure to receive a...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending November 22, 2019

Carlton Fields on

Real Property Update - Foreclosure / Rehearing: Order denying rehearing on summary judgment motion and denying continuance affirmed where (1) affidavit in support of rehearing failed to disclose any genuine issue of...more

Seyfarth Shaw LLP

Fifth Circuit Rules That The EEOC Can’t Mess With Texas Over Criminal Background Checks

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Seyfarth Synopsis: In the latest battle of the multi-year showdown between the State of Texas and the EEOC – whereby Texas asserted that the EEOC’s 2012 “Enforcement Guidance on the Consideration of Arrest and Conviction...more

Womble Bond Dickinson

Does a violation of FCRA’s “Stand-Alone” disclosure requirement confer standing or not?

Womble Bond Dickinson on

Could there be a split brewing with regard to standing to pursue FCRA claims against potential employers for violating the stand-alone disclosure requirement contained in 15 U.S.C. § 1681(b)(2)(A)(i)? Maybe....more

Womble Bond Dickinson

FCRA Disclosures: Too Much Information, Not Enough, or Just Right?

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The Northern District of California recently considered a case where a plaintiff alleged that her employer’s FCRA disclosure both had too much information and too little. Soman v. Alameda Health Sys., No. 17-CV-06076-JD, 2018...more

Womble Bond Dickinson

Reminder: Confusing Background Check Disclosures Can Get an Employer in FCRA Hot Water!

Womble Bond Dickinson on

On November 29, 2018, the Ninth Circuit Court of Appeals issued a decision in Mitchell v. Winco Foods, No. 17-35998, 2018 U.S. App. LEXIS 33483 (9th Cir. Nov. 29, 2018); a Fair Credit Reporting Act (“FCRA”) case on appeal...more

Womble Bond Dickinson

False report of prison time satisfies Spokeo’s requirement of injury in fact

Womble Bond Dickinson on

In Landry v. Thomson Reuters Corp., 2018 U.S. Dist. LEXIS 162741 (D. N.H. Sept. 24, 2018), a putative class action, a key issue was whether the Plaintiff’s amended complaint–which alleged Thomson Reuters Corporation (“TRC”)...more

Littler

Third Circuit Holds Individual Plaintiffs Lack Standing for Some Alleged Violations of the FCRA's Pre-Adverse Action Notice...

Littler on

On September 10, 2018, in Long v. Southeastern Pennsylvania Transportation Authority (SEPTA), the U.S. Court of Appeals for the Third Circuit joined the chorus of recent circuit court opinions tackling the question of...more

BCLP

Dutta: The Ninth Circuit Strikes Another Blow to FCRA Plaintiffs

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On July 13, 2018, the United States Court of Appeals for the Ninth Circuit affirmed summary judgment against a plaintiff that lacked Article III standing to assert a claim under the Fair Credit Reporting Act, 15 U.S.C. §...more

Fenwick & West LLP

Procedural FCRA Violation Without Harm is Insufficient for Standing, 9th Circuit Rules

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The U.S. Court of Appeals for the Ninth Circuit held on July 13 that procedural violations of the Fair Credit Reporting Act without actual harm were insufficient to confer Article III standing. The court found in Dutta v....more

Foley & Lardner LLP

California Federal Court Strikes Down FCRA Claim

Foley & Lardner LLP on

Earlier this month, in a case pending in the U.S. District Court for the Central District of California, Home Depot avoided a class action suit under the Fair Credit Reporting Act (FCRA). The lawsuit accused the company of...more

Carlton Fields

Still Standing: Ninth Circuit Again Finds Standing in Spokeo Remand

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The Ninth Circuit recently issued its latest opinion in Spokeo, Inc. v. Robins, the closely-watched putative class action dating back to 2010. The plaintiff initiated the lawsuit against Spokeo, which aggregates publicly...more

Proskauer - Minding Your Business

Concrete Enough to Stand: Ninth Circuit Upholds FCRA Claims in Spokeo

On August 15, 2017, the Ninth Circuit delivered the latest episode in the Robins v. Spokeo saga, reaffirming on remand from the Supreme Court that plaintiff Robins had alleged an injury in fact sufficient for Article III...more

Dechert LLP

Ninth Circuit Revisits Standing Analysis for Statutory Claims in Spokeo

Dechert LLP on

On remand from the Supreme Court, the U.S. Court of Appeals for the Ninth Circuit has held for the second time that the plaintiff in Robins v. Spokeo, Inc. has standing to proceed in federal court with claims under the Fair...more

Fenwick & West LLP

The Seventh Circuit Finds No Standing in FCRA Case Based on Job Application Credit Reports

Fenwick & West LLP on

The U.S. Court of Appeals for the Seventh Circuit held that allegations that prospective employers obtained consumer reports in technical violation of the Fair Credit Reporting Act by themselves do not constitute a concrete...more

Hinshaw & Culbertson LLP

Job Applicant Who Filed 562 Applications Then Alleged FCRA Violations Denied Standing by Seventh Circuit

We have another court decision relying on the Supreme Court's recent Spokeo decision that found a class action plaintiff did not meet the injury-in-fact requirement under Article III of the United States Constitution. In...more

Jackson Lewis P.C.

Use Of Non-Compliant Disclosure Form Did Not Result In Concrete Injury Under Fair Credit Reporting Act

Jackson Lewis P.C. on

A job applicant alleging a violation of one of the procedural requirements of the Fair Credit Reporting Act (FCRA) lacked standing to sue under Article III of the United States Constitution because he failed to allege facts...more

Kramer Levin Naftalis & Frankel LLP

Advertising Litigation Report: Vol. 2, No. 2 - Consumer Privacy and Data Security

Judge Trims Proposed Class Action Over Wendy’s Data Breach - Torres v. Wendy’s Int’l, LLC, No. 16-cv-0210 (PGB) (DCI) (M.D. Fla. Mar. 21, 2017). A U.S. district court judge in Florida trimmed a proposed class action...more

Proskauer - New Media & Technology

A Host of Biometric Privacy/Facial Recognition Bills Currently Circulating in State Legislatures

We’ve written extensively about the numerous lawsuits, dismissals and settlements surrounding the Illinois Biometric Information Privacy Act (BIPA). The statute, generally speaking, prohibits an entity from collecting,...more

Carlton Fields

Nothing Crafty About Michaels’ Disclosure Under Spokeo

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A New Jersey District Court followed Spokeo’s Article III standing analysis and dismissed claims by three putative class representatives against Michaels Stores. Plaintiffs claimed that Michaels’ online employment application...more

Carlton Fields

Spokeo Gets Lyft Off

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The Northern District of California dismissed a Fair Credit Reporting Act case against Lyft upon finding that plaintiff lacked Article III standing based on the Supreme Court’s decision in Spokeo, Inc. v. Robins, 136 S. Ct....more

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